This letter is in response to Enforcement Advisory Council (EAC)
Resolution 2007-02, dated October 15,
2007, and passed at the January 25, 2007 EAC meeting.

This EAC resolution requested actions to clarify the issues
regarding the permit application form (Excel
|
PDF)
by assisting LEAs to determine consistent permitted maximum
capacity, providing the rationale for adding the beneficial
reuse tonnage to the peak daily tonnage, conducting a workshop
to fully discuss the history, intent, and final permit
application, and revising the permit application form
(regulatory change) to address the quandary concerning the
application form showing that the peak daily tonnage may have
increased when there has been no waste flow change at the
facility.

Before taking one or more of the suggested actions outlined
in the resolution, I suggest that a workgroup be formed that
would include LEAs and Board staff. The resolution describes the
key issues and will be a good starting point for the group. The
workgroup would be tasked with sorting through the details of
the issues and developing specific recommendations to address
the problems they identify. To this end I have asked Mary
Madison-Johnson and additional staff to join with the LEAs you
select to form the workgroup. The forth coming LEA Roundtables
could be a forum for soliciting LEAs to participate. Please
provide Mary with the names of the LEAs that will participate in
the workgroup and she will facilitate getting the effort
started. She can be reached at (916) 341-6329.
I would ask that the workgroup not be tasked with implementing
any of the recommendations but would be asked to provide their
assessment and recommendations to the EAC and me for further
action.